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2021 (4) TMI 1309 - BOMBAY HIGH COURTUnexplained investment in land - AO made addition as deemed income being unexplained investment in land shown less in the balance sheet of the appellant - Substantial question of law or fact - CIT-A also after considering the oral and documentary evidence, recorded the findings that there was unexplained investment in land shown less in the balance sheet of the appellant and dismissed the appeal filed by the appellant - Tribunal has also recorded various findings of fact while dismissing the appeal preferred by the appellant - HELD THAT:- As the appellant vehemently urged that on the basis of photocopy of the agreement for sale between Shri Ayub Haji Abdul Rashid Qureshi and Shri Rajansingh Kuvarsingh Baisthkur, the assessing officer could not have made an addition in the income of the appellant. Learned counsel for the appellant could not dispute that the appellant had cross-examined Shri Rajansingh Kuvarsingh Baisthkur. Even in the cross-examination of the said seller Shri Rajansingh Kuvarsingh Baisthkur, he admitted that he had received the sum of ₹ 30.55 lakhs out of which ₹ 2 lakhs was received by cheque and balance amount of ₹ 23.50 lakhs was received in cash. The entire order passed by the Income Tax Appellate Tribunal is based on pure findings of fact. No substantial question of law arises in this appeal filed under Section 260A of the Income Tax Act, 1961. The appeal being devoid of merit is accordingly dismissed.
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